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Home My WebLink About02-27-08 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA ORPHANS' COURT DIVISION IN RE: ESTATE OF ANNA RUNK, DECEASED No. 21-08-0017 AFFIDA VIT OF SERVICE I, Catherine Klobucar, being duly sworn according to law, depose and say the following: 1. A Citation for the Petition for Citation to Grant Letters of Administration, filed in the above-captioned matter, was issued to Robert Runk on January 7,2008. 2. I have conducted a diligent search of the public records utilizing Westlaw, and the last known address for Robert Runk is P.O. Box 171, Dry Run, P A 17220. The public record search findings are attached hereto as Exhibit "A." 3. On January 9,2008 the Petition for Citation to Grant Letters of Administration and subsequent Citation were sent via certified and regular mail to Robert Runk. A copy of the service documents are attached hereto as Exhibit "B." 4. On February 15, 2008, the certified mail was returned by the United States Postal Service with a notation that is was "unclaimed." A copy of the returned certified mailing envelope and the search from United States Postal Service evidencing the return of the certified mailing is attached hereto as Exhibit "e." 5. As of today's date, the regular mail was not returned. Dated: ,J.. I ~d. In,,; _~tN...vv,..) ~.(.f,/OA1vO Catherine Klobucar ' ! , ,; Sworn to and Subscribed before me :-".. this J..JI~ay of ') \""--) --.I , 2008. I J ~r"!) _c_ -..4 CO,.) 0) v C~LmOF~NMYLV A NOTARIAL SEAL CHRISTY A. LONG, Notary Public City of Harrisburg, Dauphin County Commission Ex ires December 22, 2009 .II "6"'" .. VJ. .. PEOPLE FINDER - HISTORIC TRACKER RECORD Information Current Through: 11- 30- 2007 Database Last Updated: 12-06-2007 Update Frequency: MONTHLY Current Date: 12/26/2007 Source: TRANS UNION INDIVIDUAL INFORMATION Name: RUNK, ROBERT W Also Known As: WILLIAM, RUNK ROBERT RUNK, ROBERT SSN: 186- 50- XXX X Date of Birth: 03/1961 On File Since: 11/01/1995 Phone Number 1: 349- 2660 CURRENT ADDRESS INFORMATION Current Address: PO BOX 171 DRY RUN, PA 17220-0171 10/15/2005 Address Last Reported: PREVIOUS OR ADDITIONAL ADDRESS INFORMATION Previous Address: 21132 PARSON RD DRY RUN, PA 17220-9711 10/01/1995 Address Last Reported: END OF DOCUMENT https://web2.westlaw .com!resu]t/documenttext.aspx?rltdb=CLID _DB031152612&docsa... 12/2612007 EXHIBIT lIB" SCHUT JER I BOGAR ll.C attorneys & consultants Email: cklobucar@schutjerbogar.com Direct Dial: (717) 909-7002 January 9, 2008 VIA REGULAR & CERTIFIED MAlL Robert Runk P.O. Box 171 Dry Run, P A 17220 In Re: Estate of Anna Runk, Deceased D.C. No. 21-08-0017 Dear Mr. Runle Enclosed please find a copy of a Petition for Citation to Grant Letters of Administration, Preliminary Decree and Citation issued by the Cumberland County Register of Wills in the above-captioned matter. Additionally, we are sending a duplicate copy of the enclosed documents to you via certified mail. We kindly request that if you are not available to sign for the delivery by your regular postal carrier that you please pick up your mail at your local post office as we are required to provide the Court with proof that you have received the enclosed Petition and Citation and that you made aware of the hearing date and time. If you should have any questions, please contact Maria Macus-Bryan at (717) 909- 8640. Thank you. Sincerely, ~JWlLC Catherine Klobucar Paralegal Enclosures 2,O~J N. Front Stl'eet, Suite 40'!. Harrisburg. PA. 17101 · Fax (717) 909-5925 .. wvvw.schutj8rbogar.colTl CITATION Office of the Register of Wills Cumberland County, Pennsylvania IN RE: Anna Runk 21-08-0017 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND TO: Robert Runk Mark Runk Steven Runk Susan Feagley Michael Runk Albert Gartz GREETINGS: AND NOW this 7th day of January, 2008, the Clerk of Orphans' Court of Cumberland County issues this citation upon know heirs of Anna Runk to Compel the Production of a Will, if any, and if no Will exists to Show Cause, if any there be, why Letters of Administration for the Estate of Anna Runk, deceased, should Dot be issued to ShauD E. O'Toole, Esquire. This citation is returnable 20 days from the date of Service. Glenda Farner Strasbaugh Clerk of Orphans' Court o ~O 'cg~o --~~~ ~:IJ :J"';^- - '-'0 :~~O---;-J '.~-_.' '-- --" :-o~ --> C-- ::Do> Z I --.I -0 :JS:: W ..s::- o .=:=1 =<=-,nl ill '-~-) ':::;--JO c:..:} =0 ---c CJ rTI01 ~:; Co c.-:IO -:-! -11 <: :::!] ~:c~ '-~ _:--= D, ~:"");~ BEFORE THE REGISTER OF WILLS OF CUMBERLAND COUNTY, PENNSYLVANIA EST A TE OF ANNA RUNK DECEASED NO 21-08-0017 DECREE OF THE REGISTER OF WllLS AND NOW, this 7th day of January, 2008, upon consideration of the annexed Petition of Golden Living Center-West Shore Health and Rehabilitation, a principal creditor of Anna Runk, deceased, it is hereby Ordered and Decreed that a Citation shall be issued upon the known heirs of the Decedent to Compel the Production of a Will, if any, and if no Will exists, to Show Cause, if any, why Letters of Administration for the Estate of Anna Runk, deceased, should not be issued to Shaun E. O'Toole, Esquire, and in the interim, ShaUll E. O'Toole, Esquire, is appointed Limited Administrator Pendente Lite, with such appointment to lapse upon the granting of Letters of Administrator pursuant to 20 Pa. C.S. ~ 3155. This citation is returnable 20 days from the date of Service. Glenda Farner Strasbaugb, Register of Robert Runk Mark Runk Steven Runk Susan Feagley Michael Runk Albert Gartz o c" ~4~:~ ." ~/~ Sj __ n_. c'.'--j::;'>-::: (""0 <= <.:::) = (- :Po I -.I _.....1 rOT: ,0\-: .:-:' C-~'03 .. c-; :'c, '--"; '~J ':~ c:< . . ._;-i "'- j~;~ =:j :a -0 :::g: w W \.0 C, :1'1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: ESTATE OF ANNA RUNK, DECEASED No. of 2008 PETITION FOR CITATION TO GRANT LETTERS OF ADMINISTRA TION PURSUANT TO 20 Pa.C.S. & 3155 TO THE ORPHANS' COURT OF CUMBERLAND COUNTY: Golden Living Center - West Shore Health and Rehabilitation ("Petitioner"), a principal creditor of Anna Runk, respectfully represents that: L Petitioner operates a skilled nursing facility located at 46 Erford Road, Camp Hill, P A 1701 L 2. On or about July 22, 2005, Decedent was ad:mjtted to Petitioner's skilled nursing facility pursuant to an Admission Agreement pursuant to which Petitioner agreed to provide Decedent with skilled nursing care and services in return for her promise to make timely payment for that skilled nursing care and services. 3. As of the date of Decedent's death, as outstanding balance was owed to the Petitioner for the skilled nursing care and services it provided to her, and Petitioner was a principal creditor of Decedent. 4. Upon information and belief and to the extent of Petitioner's knowledge, on September 7, 2007, Anna Runk ("Decedent") died intestate. An original death certificate is attached as Exhibit" A." 5. Upon information and belief and to the extent of Petitioner's knowledge, Decedent has the following surviving heirs or next of kin: Name Relationship Address Robert Runk Son P.O. Box 171 Dry Run, P A 17220 Mark Runk Son 111 E Dunlap Ave. Phoenix, AZ 85020-2807 Steven Runk Son 1013 Oyster Mill Road Camp I-lill, P A 17011-1002 Susan Feagley Daughter 14557 Mountain Green Road Willow Hill, PA 17271-9703 Michael Runk Son P.O. Box 172 Willow Hill, PA 17271-0172 Albert Gartz Brother P.o. Box 607 Delta Junction, AK 99737-0607 6. Petitioner desires to have Shaun E. O'Toole, Esquire (" Attorney O'Toole"), appointed by the Court to administer the Estate of Anna Runk for the purpose of paying all debts owed by Decedent, qualifying the Decedent for the receipt of Medical Assistance benefits, and distributing the balance of the estate pursuant to the intestate laws of the Commonwealth of Pennsylvania. 7. Attorney O'Toole is a disinterested party who has no interest in the outcome of the pending Medical Assistance appeal involving the Decedent. 8. In furtherance of this matter, Petitioner also requests the appointment of a Limited Administrator Pendente Lite, pursuant to 20 Pa. C.S. ~ 3160, solely for purposes of appealing and preserving Anna Runk's eligibility for Medical Assistance benefits. 2 9. The appeal regarding Anna Runk's eligibility for Medical Assistance benefits is currently pending before the Bureau of Hearings and Appeals of the Department of Public Welfare of the Commonwealth of Pennsylvania. Because a hearing will be scheduled in this matter in the near future, it is essential that the appropriate legal representative is available to represent Ms. Runk's interests. Otherwise, her eligibility for benefits may be lost. WHEREFORE, Petitioner, Golden Living Center - West Shore Health and Rehabilitation, respectfully requests that a Citation be issued pursuant to 20 Pa. C. s. 9 3155 upon the known heirs of Anna Runk to Compel the Production of a Will, if any, and if no Will exists to Show Cause, if any there be, why Letters of Administration for the Estate of Anna Runk, deceased, should not be issued to Shaun E. O'Toole, Esquire, and in the interim that Attorney O'Toole be appointed as Administrator Pendente Lite. Respectfully submitted, ScHU1)ER BOGAR LLC I)ate:II'ZJ'~~ . llY~~ ~rkS.Sohonage . Attorney LD. 77851 (717) 909-8160 Maria G. Macus-Bryan Attorney LD. 90947 (717) 909-8640 417 Walnut Street, 4th Floor Harrisburg, PA 17101 Fax No.: (717) 909-5925 Attorneys for Petitioner VERIFICA nON The undersigned hereby verifies that the statemc::nts of fuct in the foregoing Petition are true and correct to the best of my knowledge, information and belicl. I undelb'tand that <my fulse statements therein are subject to the penalties contained in 18 Pa. C. S. S 4904, relating to unsworn falsincation to authorities. D~ted; 11--/211( D1 ~Wr ~~Dffdl . vcrly F N g Home Administrator Golden U\'mg Center - West Shore Health and Rehabilitation EXHIBIT ~~ A" .A SENDER: COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mail piece, or on the front if space permits. 1. Article Addressed to: ~c:tx2J -T ~~ n 'C:. \? . c). boX \1 \ I) "1 Lux'\ J r r\- \ I d-:d-O 2. Article Number (Transfer from service label) PS Form 3811, February 2004 COMPLETE THIS SECTION ON DELIVERY A Signature o Agent o Addressee B. Received by (Printed Name) I C. Date of Delivery D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No x 3.~ice Type Certified Mail 0 Express Mail o egistered 0 Retum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 7006 0810 0006 1052 3540 Domestic Return Receipt :;,>; ;....t; ,-, ;~ !.~j ~ ;ns ;-J p:j .Go pj '-3>' 8 ..:-~ m ~ ~~ t'" q ~~ ~~~8ZZ n ;-.'lHL-"i.,l (j()~C: . . .-, {L ~.!j ~ {I.} Jot:je~n'! Z~t:lZ U~ tJ M~ t'i ~~ );l:1 !~, i:.) o 1-' v; m' IV (j Al' OtT1 >-<. O:l ~ lVo:l ,~ C:O>-l~ , >< IV ~ '"d Ct::t .>-~ ~'~ o ~ ~ Q ::t; ~ ~ r' C1 <':) 1;-) '- r' '.0 '. c m 102S9S-Q2-M-1540 ." - :D en -I "'"en ~n ~::I: ~ Q z...... Si rT:l rJl~ >-It:l:l ~ 0 tT1 C':l ~;; 5!t"'4 ~t"'4 8(') :tJ o r- :J> en en f rJ> tl:l c:: ::<:I 9 ~ .... ;::l o .... 3: :J> - r- ~).) ~ " -', ,ijD~,n 2 ii -' _~V;;J Q. '"b? ~_.:!'!5,- :::t.~- ~ ~ :;. :: ~ ~i ' if c, _ '. - Q _, 1,..".." - ~, ~ ~ "f -~.~~ a ~. .9 ; ~ '^ J r9 Ii ! It I ff;~ ..... r', .A .& ,.. ~ - ! - - t C/ c.9 --...I 0 - 0 a- - - 0 0> I::-' 0 0 - - 0 - 0 a- I::-' 0 l.n ru w l.n ..l:' 0 j: g ~ UNjT~ rr~ ~-:; ~ J.o,:;:, C1~ u ~'f''"'-''~ ~ '" i' c: ,. ~ ~~wll~~ g~~~~" 00 '" '"II ~~01~ I u ~r ~ - J raCK c.: LUI1l1rrn rage J UI J ,,;;1 UNITED STllTES POSTAL SERVICE, Home I Help Irf3<::K& Confirm Track & Confirm Search Results Label/Receipt Number: 7006 0810 000610523540 Status: Unclaimed Track & Confrm Your item was returned to the sender on February 15, 2008 because it was not claimed by the addressee. Enter Label/Receipt Number. Addifjoual Details .> Retllm to usps. com Homo .> NDtll:caliun Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Go,. Site rv1a~' Us SE~VtCeS .hbs Privac;.y.PoFcy Terms of Use Nations! & Pre ,)ie.- CopyrightC~ 1899.2007 USPS 4i1 PeservBd. r'-Eh_p /\(1 EEe) FCj/\ . ~,. i7 http://trkcnfrml.smi.usps.comIPTSInternetWeb/InterLabel Inquiry .do 2/18/2008